Compliance guidelines for hazardous sites

Yes — a written occupational safety and health program must be developed before work begins and implemented as work proceeds for hazardous waste site clean-ups. The appendix explains that the program is an extension of the employer’s overall safety program and must facilitate coordination, hazard identification and control, training, and monitoring of program effectiveness; see Appendix C to 1910.120 - Compliance Guidelines and the general program requirement in 1910.120.

The site occupational safety and health program should be headed by the site coordinator or the employer's representative, who is responsible for protecting employees and coordinating safety issues among all parties on site. Appendix C states the site coordinator's role includes authority and responsibility for implementing the program and coordinating with contractors and support services; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120.

Yes — employers involved in treating, storing, or disposing hazardous waste covered by paragraph (p) must implement an employer safety and health program that includes a hazard communication program and the specific training required by paragraphs (p)(7) and (p)(8). Appendix C highlights that these elements must be part of the employer’s comprehensive safety program; see 1910.120(p) and Appendix C to 1910.120 - Compliance Guidelines.

Yes — each contractor on the site must have its own safety and health program structured to interface smoothly with the site coordinator’s or principal contractor’s program. Appendix C specifies that contractor programs should define safety responsibilities for their employees and coordinate with the site's overall program; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120(p).

The program must be in writing and include policy statements on authority and accountability, methods for identifying and controlling hazards, how plans and procedures will be developed and communicated, training methods for supervisors and employees, emergency preparedness, and mechanisms for feedback and program evaluation. Appendix C lists these required elements and emphasizes continual improvement; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120.

Training for employees covered by paragraph (e) must address the hazards they should expect on cleanup sites, effective control measures, monitoring procedures for exposure characterization, what makes an effective safety and health program and site safety plan, hands-on PPE training, relevant portions of the OSHA standard, and employee responsibilities under OSHA. Appendix C lists these topics and also specifies supervisor training on program elements such as spill containment and emergency response; see 1910.120(e) and Appendix C to 1910.120 - Compliance Guidelines.

Employers subject to paragraph (p) must train employees on the employer’s safety and health program elements that affect them, the hazard communication program, the medical surveillance program, and the job-specific hazards and controls they need to know. Appendix C ties the hazard communication requirement in 1910.120(p)(1) to the training requirements in 1910.120(p)(7) and 1910.120(p)(8); see Appendix C to 1910.120 - Compliance Guidelines.

Emergency responders covered by paragraph (q) must receive training appropriate to their response level on hazards of hazardous substances, hazard recognition, notification, PPE and respirator use, decontamination, incident preplanning and command system use, with hands-on training emphasized; they must receive annual refresher training. Appendix C describes the competencies for awareness, operations, technician, and specialist levels and explicitly states "All require annual refresher training"; see 1910.120(q) and Appendix C to 1910.120 - Compliance Guidelines.

Yes — hands-on training with the personal protective equipment and clothing employees will be expected to use is required to develop the necessary skills and knowledge. Appendix C calls for hands-on PPE training for cleanup workers and for hazardous materials specialists, and ties PPE training to the employer’s training program under 1910.120; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120(e).

Refresher training must be provided at least annually. Appendix C states that training for the various covered employee groups requires an annual refresher; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120.

Decontamination procedures must be tailored to the specific hazards and may vary in complexity and steps depending on the hazard level and employee exposure; one method may not work for all substances. Appendix C advises that decontamination and PPE decontamination methods depend on the specific substance and exposure, and should be evaluated to prevent exposure when reusing PPE; see Appendix C to 1910.120 - Compliance Guidelines and the referenced U.S. Coast Guard manual cited in Appendix C.

Yes — employers should evaluate decontamination methods and procedures as necessary to ensure employees are not exposed by re-using PPE. Appendix C explicitly recommends performing evaluations and cites Appendix D and the U.S. Coast Guard manual (COMDTINST M16465.30) as guidance for establishing effective decontamination programs; see Appendix C to 1910.120 - Compliance Guidelines and 6465.30.

Employers must ensure their emergency response plan is compatible with state and local district emergency response plans and use those local plans as resources when developing the employer plan. Appendix C instructs employers to utilize state and district plans and reference documents like NRT-1 and the Emergency Response Guidebook; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120(q).

Yes — elements of a properly addressed contingency plan at treatment, storage, and disposal facilities may be substituted into the emergency response plan required by 1910.120 or kept together for employer and employee use. Appendix C clarifies that employers with required contingency plans need not duplicate planning elements already covered by those plans; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120(q).

The two basic objectives are to protect the wearer from safety and health hazards and to prevent injury to the wearer from incorrect use or malfunction of the PPE. Appendix C describes these objectives and stresses that PPE be used with other protective methods and periodically evaluated; see Appendix C to 1910.120 - Compliance Guidelines.

Yes — over-protection can create hazards such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication. Appendix C warns that no single PPE combination protects against all hazards and advises selecting equipment that provides adequate protection without creating new risks; see Appendix C to 1910.120 - Compliance Guidelines.

Yes — accidents and injuries must be investigated to determine corrective actions to prevent recurrence, and the information should be used as feedback to improve program effectiveness. Appendix C requires investigation of incidents and using findings to take positive preventive steps; see Appendix C to 1910.120 - Compliance Guidelines.

Yes — Appendix C recommends using professional safety and health personnel (for example, Certified Safety Professionals or Board Certified Industrial Hygienists) to develop and administer employer programs to achieve effective implementation. Relying on qualified professionals improves planning and program administration; see Appendix C to 1910.120 - Compliance Guidelines.

Yes — employee suggestions and complaints are valid feedback mechanisms that employers should use to evaluate and improve the safety and health program. Appendix C highlights receipt of employee input as a useful evaluative tool and part of continuous program improvement; see Appendix C to 1910.120 - Compliance Guidelines.

OSHA recommends using the Hazardous Materials Emergency Planning Guide (NRT-1), the Emergency Response Guidebook from the U.S. Department of Transportation, CHEMTREC resources, and the Fire Service Emergency Management Handbook as references when developing emergency response plans. Appendix C lists these resources and directs employers to align their plans with state and district plans; see Appendix C to 1910.120 - Compliance Guidelines and 1910.120(q).

The written PPE program must include hazard identification, medical monitoring, environmental surveillance, selection, use, maintenance, decontamination of PPE, and associated training. Employers should also include clear policy statements, procedures, and guidelines, and make copies available to all employees and a reference copy at the worksite as part of the program (see 1910.120AppC and the general HAZWOPER requirements in 1910.120).

• Keep technical data, maintenance manuals, and relevant regulations with the written program so supervisors and responders can access them quickly.
• Use the written program to document who is responsible for each element (selection, maintenance, decontamination, training).

Employers must provide copies of the written PPE program to all employees and keep a reference copy available at the worksite, along with technical data and maintenance manuals. The guidance in 1910.120AppC specifically advises collecting and maintaining technical data, maintenance manuals, relevant regulations, and other essential information with the written program (see also 1910.120).

• Make sure employees know how to access the program and related documents during normal operations and emergencies.
• A single, clearly labeled reference copy at the incident site helps supervisors and responders find procedures quickly.

The individual in charge of the ICS is the senior official responding to the incident who assumes overall command and management of operations. OSHA explains that the ICS places one individual in charge so one person makes strategy, tactics, and decisions, with subordinates assigned tasks by that commander (see 1910.120(q)(3)(ii) and 1910.120AppC).

• That person performs the initial size-up, decides whether more resources are needed, and designates subordinate officers or functions.

All communications should be coordinated through a single command post or central point so messages are routed and decisions are centralized. OSHA's discussion of the ICS highlights routing communications through the command post to reduce radio traffic and confusion, with strategy and decisions made by the one individual in charge (see 1910.120AppC and 1910.120(q)(3)(ii)).

• Use clear radio protocols, designate communication liaisons, and ensure everyone knows the command post frequency and procedures.

Yes; for small incidents the individual in charge of the ICS may perform many roles (for example, acting as the safety officer) but OSHA recommends designating at least two backup employees to assist or perform rescue if needed. The guidance explains that on small incidents the commander may take on several ICS tasks and should designate backup personnel—OSHA specifically recommends at least two backups because assistance might include rescue (see 1910.120AppC).

• If the commander doubles as safety officer, document the temporary assignment and ensure backups have proper training and equipment.

Decontamination procedures are required when the nature and extent of contamination could expose responders or others to hazardous materials; for very small, isolated leaks with no expected contamination of personnel or equipment, decontamination may not be necessary. OSHA's example of a small overturned tank truck with a small leak notes that if additional assistance is not needed and tasks can be handled with the fewest people, decontamination procedures may not be required in that scenario (see 1910.120AppC and the broader HAZWOPER rule in 1910.120).

• Base the decision on hazard assessment, potential for contact or contamination of clothing/equipment, and agency procedures.
• If any responder or equipment will contact the spilled material, implement decontamination procedures and a decon area as described in the Site Safety and Control Plan.

At large incidents the incident commander should delegate tasks to subordinate officers either by geographic sectors (location) or by function (medical services, evacuation, water supply, safety, site control, etc.) to maintain an effective span of control. OSHA guidance recommends dividing the incident scene into sectors or delegating by functions to keep reporting lines manageable and to assign safety officers and backups as needed (see 1910.120AppC and 1910.120(q)(3)(ii)).

• Establish clear command roles and written or radio-confirmed task assignments so subordinates know their responsibilities.

A comprehensive Site Safety and Control Plan should include a hazard summary and risk analysis, site map, defined work zones (clean, transition/decon, hot), buddy system, site communications, command post location, standard operating procedures, medical/triage area, hazard monitoring plan, decontamination procedures and area, and any other site-specific needs. OSHA explicitly lists these elements and recommends the plan be part of or an extension of the employer's emergency response plan (see 1910.120AppC and related 1910.120(q)).

• Ensure the plan is written, available at the site, and tailored to the hazards expected at that location.

Site work zones are designated areas such as the clean zone, transition (decontamination) zone, and hot (work) zone used to control access, limit contamination spread, and protect responders. OSHA advises establishing these zones in a Site Safety and Control Plan to separate contaminated operations from support and recovery activities (see 1910.120AppC).

• Use physical barriers, signage, and access control lists to keep unprotected personnel out of hot zones.
• Place decontamination between hot and clean zones so contamination is removed before personnel re-enter the clean area.

A medical surveillance program is essential to assess and monitor workers' health and fitness for hazardous waste operations, provide emergency care, and keep accurate medical records for future reference. OSHA's guidance explains that hazardous site work can involve chemical, biological, radiological, and physical dangers, and recommends medical surveillance as part of a comprehensive protection program (see 1910.120AppC and 1910.120).

• Follow the medical testing examples and recommendations found in recognized guidance such as the joint OSHA/NIOSH manual cited in the App C text.

Workers performing spill control must be trained in the employer's standard operating procedures, the use and care of spill control equipment, and the hazards and controls associated with spill containment and treatment agents. OSHA states that all involved workers need training in SOPs, equipment use/care, and associated hazards for spill containment work (see 1910.120AppC).

• Training should include manufacturer instructions for new agents, application methods that allow remote application where possible, and emergency procedures if an application goes awry.

Yes; when applied according to the manufacturer's instructions, solidifying agents and vapor suppression products can reduce worker hazards by containing liquids, reducing vapor generation, neutralizing acids/caustics, or adsorbing vapors. OSHA's guidance describes modern agents that solidify liquids, suppress vapors, or neutralize corrosives and notes their benefits for rapid containment and safer cleanup (see 1910.120AppC).

• Ensure selection and use of these agents are part of the employer's spill containment and new technology program, and that responders are trained in safe remote application methods when available.

Apply vapor suppression and solidifying agents from a safe distance using remote applicators or nozzle/hose systems and follow manufacturer's instructions, because rapid and uniform application can provide quick vapor knockdown and reduce inhalation or ignition risks. OSHA recommends use of portable pressurized applicators or hose/nozzle systems that allow operators to apply agents from remote positions for volatile substances (see 1910.120AppC).

• Ensure appropriate PPE, monitoring for vapors, and that the chosen agent does not create a new hazard (e.g., exothermic reaction).

Employers should evaluate new products and application techniques as part of a formal new technology program, considering manufacturer instructions, compatibility with the spilled material, required PPE, application methods that minimize worker exposure, and training needs. OSHA suggests that employers include new agents and tools in their evaluation process to complement traditional containment methods (see 1910.120AppC).

• Pilot-test new agents under controlled conditions, document standard operating procedures, and train responders before using them on emergency incidents.

The resulting material may be less hazardous and easier to handle, but whether it can be treated as nonhazardous depends on meeting applicable environmental regulations such as EPA waste criteria; OSHA notes that some agents can elevate flashpoints above 140 °F and that handling/disposal decisions must consider the EPA's 40 CFR part 261 criteria (see 1910.120AppC).

• Coordinate with environmental authorities and waste management experts to confirm whether treated material meets nonhazardous waste criteria before disposal.

Employers should select PPE based on a thorough hazard identification and risk assessment that considers the specific hazardous substances, potential exposures, and operations being performed. OSHA's guidance ties PPE selection to hazard identification, environmental surveillance, and medical monitoring as part of a comprehensive PPE program (see 1910.120AppC and 1910.120(p)(1)).

• Use monitoring data (air sampling, etc.), chemical properties, and manufacturer exposure limits to decide between levels of protection and respiratory options.

The employer or the designated incident commander should ensure that the Site Safety and Control Plan, hazard assessments, SOPs, and relevant records are maintained and available at the worksite for responders. OSHA emphasizes having written plans, policy statements, and technical data available at the worksite as part of an effective protective program (see 1910.120AppC).

• Keep copies of monitoring results, PPE maintenance logs, medical surveillance records, and decontamination procedures accessible to the ICS and safety officers during the incident.

Backup personnel provide immediate assistance or rescue support and are designated to ensure someone is available to help responders who become incapacitated; OSHA recommends at least two backup personnel even for small incidents because assistance may include rescue (see 1910.120AppC).

• For large incidents, the incident commander should designate several backup personnel and a number of safety officers to monitor conditions and recommend safety precautions.

OSHA notes that treatment of spills during immediate containment and control efforts is sometimes acceptable to EPA and that certain EPA permit exceptions may apply for emergency spill treatment activities. The App C guidance specifically references EPA permit exceptions for treatment during containment at emergency incidents (see 1910.120AppC).

• Always confirm with environmental authorities and document the emergency response decision and the regulatory basis before treating/discharging materials that might otherwise require permits.